- Name: Sarah Young
- Filing date: March 31, 2021
- State of filing: California
- Name: Rituals Cosmetics USA Inc.
- Website: www.rituals.com
- Industry: Beauty
- Summary: Rituals is a cosmetics and beauty supplies manufacturer.
On March 31, 2021, Sarah Young filed a Complaint in California Federal court against Rituals Cosmetics USA Inc.. Plaintiff Sarah Young alleges that www.rituals.com is not accessible per the WCAG 2.0 accessibility standard(s).
Plaintiff alleges issues in its Complaint including the following:
- Lack of Alternative Text (“alt-text”), or a text equivalent.
- Empty Links That Contain No Text causing the function or purpose of the link to not be presented to the user.
- Redundant Links where adjacent links go to the same URL address
- Linked Images Missing Alt-text, which causes problems if an image within a link contains no text and that image does not provide alt-text.
- Many pages on the Website also contain the same title elements.
- The Website also contained a host of broken links
Plaintiff asserts the following cause(s) of action in its Complaint:
- VIOLATIONS OF THE ADA, 42 U.S.C. § 12181 et seq.
- VIOLATIONS OF THE NYSHRL
- VIOLATIONS OF THE REHABILITATION ACT of 1973, §504
- VIOLATIONS OF THE NYCHRL
- DECLARATORY RELIEF
Plaintiff seeks the following relief by way of its Complaint:
- A preliminary and permanent injunction to prohibit Defendant from violating the Americans with Disabilities Act, 42 U.S.C. §§ 12182, et seq., N.Y. Exec. Law § 296, et seq., N.Y.C. Administrative Code § 8-107, et seq., The Rehabilitation Act of 1973, § 504 et seq., and the laws of New York
- A preliminary and permanent injunction requiring Defendant to take all the steps necessary to make its Website into full compliance with the requirements set forth in the ADA and the RA, and its implementing regulations, so that the Website is readily accessible to and usable by blind individuals
- A declaration that Defendant owns, maintains and/or operates its Website in a manner that discriminates against the blind and which fails to provide access for persons with disabilities as required by Americans with Disabilities Act, 42 U.S.C. §§ 12182, et seq., N.Y. Exec. Law § 296, et seq., N.Y.C. Administrative Code § 8-107, et seq., The Rehabilitation Act of 1973, § 504 et seq., and the laws of New York
- An order certifying the Class and Sub-Classes under Fed. R. Civ. P. 23(a) & (b)(2) and/or (b)(3), appointing Plaintiff as Class Representative, and her attorneys as Class Counsel
- Compensatory damages in an amount to be determined by proof, including all applicable statutory and punitive damages and fines, to Plaintiff and the proposed class and Sub-Classes for violations of their civil rights under New York State Human Rights Law and City Law
- Pre- and post-judgment interest; g. An award of costs and expenses of the action together with reasonable attorneys’ and expert fees; and h. Such other and further relief as this Court deems just and proper.